Privacy Policy

Last Revised: June 2020

This privacy policy sets out the privacy practices for Kaido Group Limited, a company incorporated in England & Wales with company number 09440706 and having its registered office at iCentrum 6 Holt Street, Birmingham, B7 4BP, United Kingdom ("we", "us", "our").

In order to provide our services to you and to promote our business, we will need to collect and process certain personal information about you.

We are committed to protecting the privacy and security of your personal information, in accordance with the applicable data protection laws, including the General Data Protection Regulation, together the “Data Protection Laws”. This privacy policy describes how we collect and use personal information about you during and after our relationship with you and your employer.

If you have any questions at all about this policy or our Platform, or about how we use and process your personal information, please do not hesitate to contact us by emailing [email protected] or, alternatively, in writing to Kaido Group Ltd, iCentrum 6 Holt Street, Birmingham, B7 4BP.

Overview

Kaido is an online platform (the Platform) designed to help people take control of their health and wellbeing.

The Platform comprises a website and apps for iOS and Android and is located at https://kaido.org and associated subdomains.

Our approach to your privacy is very straightforward to understand.

  1. We do not collect more personal information than we need
  2. We will not share any personal data you give us (e.g. your name or email address) with other third parties
  3. We try to give you as much control about what information you share as possible.

The information we collect

The information we collect can be broken down broadly into two categories:

The Information you provide to us

Information collected during account registration

During registration we collect some information about you, such as your name and email address.

We use your name and email to send you

Information you provide when using the service:

To enable us to provide quality health and wellbeing services to you, we need to collect both anonymous and personal information about you. We collect this information through your use of the Platform.

You are under no obligation to provide any such information at any time. However, should you choose not to do so, your experience of the Platform may be affected.

To help illustrate the nature of the personal information you have the option to provide to us, we have provided the following non-exhaustive examples:

Account:

From a connected health and fitness tracker:

From daily entry into the Kaido platform:

From time to time we may capture additional data points. Such additions will not be considered a material change to this Privacy Policy.

Information we collect while you use our online Services

As you use Kaido we will monitor how you use the Platform in order to maintain your state (e.g. which content you have unlocked).

We may collect usage information about your use of our Platform in order to improve your experience and provide support. This information may include:

  1. The URLs of the page you are visiting
  2. Some information about your browser's version and operating system
  3. Information about your location (based on your IP address)

Cookies

Cookies are small text files that are placed on your computer by websites that you visit. The table below explains the cookies we use and why.

Kaido's sites use the following cookies:

Cookie Scope Purpose
_kaido_session *.kaido.org A functional cookie to manage your signed-in session on our web sites
intercom-* *.kaido.org A functional cookie that allows you to contact us for support. You can learn more about Intercom's cookies here.

How we use the information we've collected

Kaido will only use or disclose the personal information you have chosen to provide us with for the purpose for which you provided it. Kaido will not use it for any other purpose without your explicit consent, except in situations listed under "Exceptional cases of data disclosure" below. We use your personal information to enable you to use our platform.

Some examples of how we will use your personal information to enable your use of the Platform include:

We may derive anonymised information from your personal data, which we may use or disclose for reporting purposes. For example, we may use or disclose anonymised information about participation in the Kaido Wellbeing challenge and aggregate performance information, and summary information about participants. We may also use or disclose this anonymised data for research purposes. For example, we may aggregate information into an anonymised data set to better understand aggregate sleep patterns and daily active movement for a defined population. In either scenario, we will not disclose information that can be linked back to you to any third party, including your employer.

As is true of most websites, our Platform gathers certain information automatically and stores it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, to analyse trends, to administer the site, to analyse your movements around the site, and to gather demographic information about our user base, in order to improve the quality of our Platform.

Access to your personal data and other sensitive information is strictly restricted to Kaido Group Ltd employees and contractors, as needed in order to operate, develop or improve the Service, and subject to specific internal procedures and safeguards. These individuals are selected in accordance with our security policies and regulations and are bound by confidentiality obligations. They may be subject to disciplinary measures, including possible dismissal and other sanctions, if they fail to meet these obligations.

From time to time, we may request other personal information to provide you with other benefits of the Service. In all such instances, you will be given the option of whether or not to provide that information, and any information you provide will be used only for the purpose stated at the time you provide that information. After that purpose is achieved, the collected personal data will be deleted.

GDPR

The GDPR (General Data Protection Regulation) is European legislation that governs how we process data originating from users from the EU. Kaido aims to be GDPR compliant for all users, even those outside the EU and you therefore have some important rights applicable to our Platform.

  1. Your Right to be Informed: This Privacy Policy details who we are, what we collect, and what we use it for.
  2. Right of access: At any time you can review the information on your profile and update or change it.
  3. Right of portability: We can provide you with a copy of your personal data in a machine readable format. Please contact [email protected] for more information.
  4. Right to Erasure: We can remove your personal data from our systems so that you can no longer be personally identified. Please contact [email protected] for more information.
  5. Right to Withdraw Consent: You can withdraw your consent to this Privacy Policy at any time. This will lead to the deletion of your data. Please contact [email protected] for more information.

Legal basis for processing

When processing individuals health data, our legal basis for data processing is based on individuals’ consent. During sign-up we obtain explicit consent to undertake this processing. You can take control of the scope of our processing by what you decide to share with us. There is no obligation for you to provide us with any health and wellbeing data and uploading that data is interpreted as consent to process each individual data point.

Occasionally we process data based on our legitimate interests. This might include, for instance, tracking application usage using data captured in our web server logs.

Exceptional cases of data disclosure:

Kaido Group Ltd may be required to disclose personal data in response to lawful requests by public authorities, as follows;

Where is my data stored?

The Kaido application runs on servers within the European Economic Area. All data stored on these services is subject to European Data Protection legislation. You data is encrypted at rest using the AES-256 encryption algorithm. Access to your data is restricted to authorised machines only and cannot be accessed via the Internet directly.

Sharing and transferring data

We do not rent or sell any Personal Information that we collect with third parties.

If you choose to publish personal information on our Platform (such as, for instance, your name on a public profile page), you will remain responsible and in control of that information. We reserve the right to remove any content we deem to be offensive or illegal.

Who does Kaido disclose my Personal Information to?

Agents and contractors

In some instances, we may disclose your Personal Information to agents or contractors that work on our behalf and assist us in providing and supporting the services we offer.

Your Employer:

When a Kaido challenge concludes, we will provide your employer with the names and contact information of the team captain of the top three teams, so that prizes and medals can be awarded.

We may also share anonymised and aggregated data with your employer in specific circumstances and for limited purposes, such as to evaluate the effectiveness of your company health and wellbeing initiatives. Your employer will not be able to use such anonymised information or aggregated reports to directly identify you. Your employer may use the anonymised information at its discretion.

If you choose to publish personal information on our Platform (such as, for instance, your name on a public profile page), you will remain responsible and in control of that information.

Access to my data

Upon request we will provide you with the information that we hold about you. If your Personal Information changes or is incorrect or outdated, you may correct, update, or amend it by making the change through the ‘settings’ section of the Platform.

Any information that you input into the system (e.g. daily steps completed, or reflections) are fully available and accessible to you at all times.

Deletion of your account

You can request deletion of your account and its associated data at anytime by emailing [email protected]

Retention of information

When your account is deleted, we will delete your associated data from our core database. Some data will persist for a limited time period within our automated backups.

Your rights

You have a legal right under data protection law to a copy of all the information held about you by us. On request we will provide you with a copy of this information. You also have a right to correct any errors in that information.

Changes to this Privacy Policy

This Privacy Policy is subject to change from time to time. We will post any revised versions of the Privacy Policy on the Kaido website. If we make material changes to it, we will also send you an email to the last email address you provided to us so that you can renew your consent and accept the new privacy policy

Contacting us

Please submit any questions, concerns or comments you have about this Privacy Policy or any requests concerning your personal data by email to [email protected] or via the 'contact us' section of the Kaido website. Alternatively, you may contact us at: Kaido Group Ltd, iCentrum, 6 Holt Street, Birmingham, B7 4BP.